Connie A. Washington - Page 32

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               There are other sections, however, where the word “remaining”          
          is used in a different context as a copula12 or linking verb.   When        
          used as a copula the word “remaining” links the word that precedes          
          it to the word that follows it;13 e.g., the income remaining                
          undistributed.  In those sections, the word “remaining” means that          
          the preceding word “continues to be unchanged” in the “form,                
          condition, or status” described by the word that follows.  We               
          believe that within the context of the effective date provisions of         
          section 6015 a tax liability “remaining unpaid” on or after July            
          22, 1998, means that the liability continues to be unpaid after             
          July 22, 1998.                                                              
               The applicability of section 6015 to the issue before us thus          
          turns on the meaning of the word “unpaid”.  The primary definition          

               11(...continued)                                                       
          application of subsection (a)”); sec. 7608(c)(3) (“such proceeds or         
          the balance of such proceeds remaining at the time”); sec. 9008(f)          
          (“moneys remaining in the account * * * moneys so remaining”); sec.         
          9038(b)(3) (“that portion of any unexpended balance remaining in            
          the candidate’s accounts”).                                                 
               12   Copulas are verbs that link a predicate (adjective, noun,         
          etc.) to the subject.  I Curme, A Grammar of the English Language,          
          par. 12.3, 66 (1986).  Copulas often indicate a state, continuance          
          in a state, or entrance into a state.  Id. par. 12.3, 68.  The verb         
          “remain” is among the most common copulas and indicates a                   
          continuance in a state.  II Curme, A Grammar of the English                 
          Language, par. 6.B, 27-28.                                                  
               13   See, e.g., sec. 411(b)(1)(A) (“benefits * * * shall be            
          treated as remaining constant”); sec. 9704(i)(1)(B) (“the expenses          
          accrued (and remaining unpaid)”);  sec. 4942(a) (“the amount of             
          such income remaining undistributed at the beginning of such second         
          (or succeeding) taxable year”); sec. 7448(j)(3) (“Any accrued               
          annuity remaining unpaid”).                                                 





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